PTAB challenges

Proceedings Overview

There is a single AIA trial proceeding on file for US patent 11233780. This proceeding resulted in a denial of institution, meaning no claims were invalidated or sustained by the PTAB. This outcome gives a defendant a relatively strong defensive posture in that the patent has not been subjected to a full PTAB trial on the merits, and its claims remain untested.

IPR2026-00114 — [[[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.) v. Network-1 Technologies, Inc.

• Type: Inter Partes Review
• Filed: 2025-11-26
• Status: Institution Denied. The PTAB declined to institute a trial.
• Judge panel: The specific judge panel information is not available from the provided search results.
• Petition grounds: The specific claims challenged, prior art references, and statutory bases (§ 102 / § 103 / § 112) for the petition are not publicly available in the search snippets.
• Institution decision: Denied on 2026-05-06. The detailed reasoning for the denial of institution is not available from the provided search results and would require reviewing the full decision document.
• Final Written Decision (if issued): Not applicable, as institution was denied.
• Settlement / termination: Not applicable, as institution was denied.
• Appeal: No Federal Circuit appeal has been noted for this proceeding, which is expected as institution was denied.
• Defensive value: The denial of institution for IPR2026-00114 means that the patent owner, Network-1 Technologies, Inc., prevailed at the institution stage. This indicates that Samsung Electronics Co., Ltd. et al. failed to show a reasonable likelihood of prevailing on at least one challenged claim, making a similar IPR-based defense using the same (or substantially the same) arguments more challenging for others.

Strategic Summary

As of the current date, all claims of US patent 11233780 are considered UNTESTED by the PTAB in a full trial on the merits. The single IPR filed, IPR2026-00114, was denied institution, meaning the PTAB did not proceed to a full review of the challenged claims. This indicates that the patent has not been narrowed or strengthened by any final written decision from the PTAB.

Regarding estoppel, since institution was denied for IPR2026-00114, the statutory estoppel provisions of 35 U.S.C. § 315(e)(2) do not apply to the petitioner (Samsung Electronics Co., Ltd. et al.) or its privies concerning any grounds that were raised or reasonably could have been raised in the petition. This means that a defendant currently facing assertion of this patent is generally free to use any prior art grounds they deem relevant, including those that may have been presented in the denied petition, as long as they are not otherwise estopped (e.g., due to prior district court judgments).

There is no discernible pattern of multiple IPRs from the same petitioner or aggressive PTAB appeals by the patent owner. The sole proceeding to date was initiated by Samsung Electronics Co., Ltd. et al., and it did not advance beyond the institution phase.

Recommended Next Steps

• For any party considering a challenge against US11233780, it is crucial to obtain and thoroughly review the full institution decision for IPR2026-00114 (Decision Issue Date: 2026-05-06). This document will provide the detailed reasoning behind the PTAB's denial, identifying specific deficiencies in Samsung's petition. Understanding these deficiencies will be vital for crafting any future IPR petitions to avoid similar pitfalls. The decision can typically be found on the USPTO PTAB E2E system by searching for IPR2026-00114.
• Given that the patent's claims remain untested by the PTAB, the absence of a trial on the merits means the patent is not "hardened" in the same way patents that survive FWDs might be. This could suggest that the patent has not faced a robust PTAB challenge or that prior challenges (like IPR2026-00114) were procedurally or substantively weak.
• Consider conducting a comprehensive prior art search to identify new and stronger grounds for invalidity, potentially addressing any weaknesses highlighted by the PTAB's decision to deny institution in IPR2026-00114.